IRS Written Determinations
Free IRS private letter rulings, technical advice memoranda, and Chief Counsel advice with plain-English summaries and the official IRS release on every page.
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PLR 201020030: IRS approved a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a plan's request for a five-year extension to amortize unfunded liabilities described in IRC § 431(b)(2)(B) and § 431(b)(4). The approval was granted under § 431(d)(1), after the…
PLR 201020029: IRS approved a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a plan's request for a five-year extension to amortize unfunded liabilities described in IRC § 431(b)(2)(B) and § 431(b)(4). The approval was granted under § 431(d)(1), after the…
PLR 201020028: IRS approved a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a plan's request for a five-year extension to amortize unfunded liabilities described in IRC § 431(b)(2)(B) and § 431(b)(4). The approval was granted under § 431(d)(1), after the…
PLR 201020027: IRS approved a five-year extension to amortize a plan's unfunded liabilities
The IRS approved a plan's request for a five-year extension to amortize unfunded liabilities described in IRC § 431(b)(2)(B) and § 431(b)(4). The approval was granted under § 431(d)(1), after the…
PLR 201020026: IRS waived the 60-day IRA rollover deadline because of the taxpayer's medical condition
The IRS waived the 60-day deadline for rolling a distribution from one IRA into a rollover IRA. The taxpayer said that declining health, mental confusion, and memory impairment prevented timely…
PLR 201020025: IRS approved a private foundation's transfer of all assets to another foundation
The IRS approved a private foundation's plan to transfer all of its net assets to another private foundation for less than full and adequate consideration. The transfer qualified under IRC §…
PLR 201020024: IRS approved a private foundation's scholarship grant program
The IRS approved a private foundation's program to award scholarships and grants for individual study at accredited colleges and universities. The program required applicants to live in the…
PLR 201020023: IRS approved stipends for students in summer internships
The IRS approved a private foundation's program to provide selected undergraduate students with one-time stipends for summer living expenses while they participate in internships. Students with…
PLR 201020022: IRS approved five years of neighborhood-land treatment, then denied later treatment
The IRS considered a church's request to use the neighborhood-land rule for property it purchased and mortgaged for future charitable use. The church initially rented the property while developing…
Determination 201020021: IRS denied exemption to an organization conducting political and social activities
The IRS made final an adverse determination denying tax exemption under IRC § 501(c)(3) to an organization that conducted member events involving educational, political, religious, social, and…
CCA 201020020: Counsel clarified judicial review of a reportable-transaction penalty
In an internal Chief Counsel email, the sender forwarded a question to the office with jurisdiction over the regulations under IRC § 6011 concerning reportable-transaction disclosures by S…
CCA 201020019: Counsel explained the presumption for a partner signing a partnership return
In an internal Chief Counsel email concerning an allegedly invalid signing of a TEFRA partnership return, the sender quoted IRC § 6063. That provision requires a partnership return to be signed by…
CCA 201020018: Counsel summarized when supplemental unemployment benefits are wages
In an internal Chief Counsel email, the sender explained that Rev. Rul. 90-72 builds on Rev. Rul. 56-249 rather than replacing it. The analysis states that supplemental unemployment benefits may…
CCA 201020017: Counsel addressed affected-item notices in a TEFRA partnership matter
In an internal Chief Counsel email concerning a TEFRA partnership matter, the sender explained the interaction among IRC §§ 6222, 6225, and 6230. The email states that § 6222 removes the restriction…
CCA 201020016: Counsel addressed withholding for a railway union representative
In an internal Chief Counsel email, the sender addressed a railway union representative whose employer was not an employer under IRC § 3231(a), requiring the worker to pay Tier I and Tier II…
CCA 201020015: Counsel discussed assessment procedures for inconsistent partnership reporting
In an internal Chief Counsel email concerning another TEFRA question, the sender addressed indirect partners holding an interest in one partnership through another partnership. The email states that…
CCA 201020014: Counsel discussed FICA liability and worker classification rules
In an internal Chief Counsel email, the sender considered the interaction among IRC §§ 3121(b)(20), 3121(d)(1), and 3509 when an employer failed to pay FICA tax. The email states that if the failure…
CCA 201020013: Counsel addressed the treatment of carryforwards
In an internal Chief Counsel email, the sender addressed how carryforwards should generally be disallowed in a TEFRA matter. The email states that carryforwards are generally disallowed through…
CCA 201020012: Counsel discussed a tenant's defense to levy on a judgment
In an internal Chief Counsel email concerning levy execution and lien priorities, the sender stated that the tenant appeared to have a defense to levy under IRC § 6332(a) because of execution on the…
CCA 201020011: Counsel directed an inquiry to totalization agreements
In an internal Chief Counsel email about social security taxes, the sender stated that the United States has totalization agreements with the United Kingdom and Germany. The email explained that…
CCA 201020010: Counsel discussed who may sign a government employer's tax documents
In an internal Chief Counsel email concerning an individual closing-agreement case, the sender stated that the regulations under IRC § 6501(c)(4) do not specify who may sign a consent. The email…
CCA 201020009: Counsel concluded that certain gift tax is not included in a nonresident's U.S. estate
In a Chief Counsel Advice memorandum, the IRS considered whether IRC § 2035(b) applies to the U.S. estate of a nonresident noncitizen under § 2104(b). The memorandum concludes that gift tax paid on…
PLR 201020008: IRS approved a planned merger of a holding company into its subsidiary
The IRS approved the merger of a holding company into its wholly owned operating subsidiary as a tax-free reorganization under IRC § 368(a)(1)(A). The ruling also approved nonrecognition for the…
PLR 201020007: IRS allowed an S corporation to continue after an inadvertent trust-election failure
The IRS ruled that a corporation's S corporation election terminated when its stock passed to trusts whose beneficiaries had not made the required qualified subchapter S trust elections. The IRS…
PLR 201020006: IRS treated omitted subsidiaries as having joined a consolidated return
The IRS ruled that three wholly owned subsidiaries could be treated as having joined their parent's initial consolidated federal income tax return even though Forms 1122 were not timely filed. The…
PLR 201020005: IRS ruled that wrongful-death compensation was excludable from gross income
The IRS ruled that compensation received from a government department for the wrongful death of a family member was excludable from gross income under IRC § 104(a)(2). The payment arose from a…
PLR 201020004: IRS ruled that wrongful-death compensation was excludable from gross income
The IRS ruled that compensation received from a government department for the wrongful death of a family member was excludable from gross income under IRC § 104(a)(2). The payment arose from a…
PLR 201020003: IRS treated a regulated investment company's Subpart F income as qualifying income
The IRS ruled that Subpart F income from a regulated investment company's wholly owned foreign subsidiary would be qualifying income under IRC § 851(b)(2). The fund intended to qualify each year as…
PLR 201020002: IRS granted extra time to make a QTIP election
The IRS granted an executor an extension of time to make a qualified terminable interest property election under IRC § 2056(b)(7). The executor had filed the decedent's estate tax return and…
PLR 201020001: IRS approved trust reformations and automatic GST-exemption allocations
The IRS ruled that judicial reformations of two substantially identical testamentary trusts would not be treated as the exercise, release, or lapse of general powers of appointment by the trusts'…
Determination 201019034: IRS reclassified a supporting organization as a private foundation
The IRS finalized an adverse determination changing an organization’s classification from a section 509(a)(3) supporting organization to a private foundation. The organization supported a specified…
Determination 201019033: IRS denied exemption to an organization providing administrative services
The IRS denied an organization’s application for exemption under section 501(c)(3) and section 501(c)(6). The organization provided accounting, administrative, payroll, and other support services to…
Determination 201019032: IRS approves a five-year amortization extension for a pension plan
The IRS approved a plan’s request for a five-year automatic extension to amortize unfunded liabilities existing on January 1, 2009. The extension applies to the plan year beginning January 1, 2009,…
Determination 201019031: IRS approves a five-year amortization extension for a pension plan
The IRS approved a plan’s request for a five-year automatic extension to amortize unfunded liabilities existing on January 1, 2009. The extension applies to the plan year beginning January 1, 2009,…
Determination 201019030: IRS approves a five-year amortization extension for a pension plan
The IRS approved a plan’s request for a five-year automatic extension to amortize unfunded liabilities existing on January 1, 2009. The extension applies to the plan year beginning January 1, 2009,…
Determination 201019029: IRS approves a five-year amortization extension for a pension plan
The IRS approved a plan’s request for a five-year automatic extension to amortize unfunded liabilities existing on January 1, 2009. The extension applies to the plan year beginning January 1, 2009,…
Determination 201019028: IRS approves a five-year amortization extension for a pension plan
The IRS approved a plan’s request for a five-year automatic extension to amortize unfunded liabilities existing on January 1, 2009. The extension applies to the plan year beginning January 1, 2009,…
Determination 201019027: IRS approves a five-year amortization extension for a pension plan
The IRS approved a plan’s request for a five-year automatic extension to amortize unfunded liabilities existing on January 1, 2009. The extension applies to the plan year beginning January 1, 2009,…
Determination 201019026: IRS approves a five-year amortization extension for a pension plan
The IRS approved a plan’s request for a five-year automatic extension to amortize unfunded liabilities existing on January 1, 2009. The extension applies to the plan year beginning January 1, 2009,…
Determination 201019025: IRS approves a five-year amortization extension for a pension plan
The IRS approved a plan’s request for a five-year automatic extension to amortize unfunded liabilities existing on January 1, 2009. The extension applies to the plan year beginning January 1, 2009,…
Determination 201019024: IRS approves a five-year amortization extension for a pension plan
The IRS approved a plan’s request for a five-year automatic extension to amortize unfunded liabilities existing on January 1, 2009. The extension applies to the plan year beginning January 1, 2009,…
PLR 201019023: IRS approves a five-year amortization extension for a pension plan
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities existing on January 1, 2009. The extension applies to the plan year beginning January…
PLR 201019022: IRS approves a five-year amortization extension for a pension plan
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities existing on January 1, 2009. The extension applies to the plan year beginning January…
PLR 201019021: IRS approves a five-year amortization extension for a pension plan
The IRS approved a pension plan's request for a five-year automatic extension to amortize unfunded liabilities existing on January 1, 2009. The extension applies to the plan year beginning January…
CCA 201019020: Chief Counsel addressed the grounds required for a refund claim
Chief Counsel advice addressed whether a refund claim adequately stated the grounds for an alternative tax net operating loss deduction under section 56(d). The advice states that, outside the…
PLR 201019019: IRS grants relief for a late S corporation election
The IRS ruled that a company established reasonable cause for failing to timely file an S corporation election. The company intended to file Form 2553 effective on a specified date but did not file…
PLR 201019018: IRS consents to a regulated investment company's revocation of a distribution election
The IRS consented to a regulated investment company's revocation of an election under IRC § 4982(e)(4)(A) for a specified tax year and later calendar years. The election had allowed the company to…
PLR 201019017: IRS treats a subsidiary as having joined its parent's consolidated return
The IRS ruled that a subsidiary would be treated as having joined its parent's initial consolidated federal income tax return even though the subsidiary was not listed on Form 851 and no Form 1122…
PLR 201019016: IRS grants extra time to elect U.S. tax deferral for a Canadian retirement plan
The IRS granted a U.S. resident an extension of time to elect the provisions of Rev. Proc. 2002-23 for a Canadian Registered Retirement Savings Plan. The election, made on Form 8891 under the…
PLR 201019015: IRS grants extra time to elect U.S. tax deferral for a Canadian retirement plan
The IRS granted a U.S. resident an extension of time to elect the provisions of Rev. Proc. 2002-23 for a Canadian Registered Retirement Savings Plan. The election, made on Form 8891 under the…
PLR 201019014: IRS grants relief for a late S corporation election
The IRS ruled that a company established reasonable cause for failing to timely file its S corporation election. The company's shareholders intended the company to be an S corporation effective on a…
PLR 201019013: IRS grants extra time to elect U.S. tax deferral for a Canadian retirement plan
The IRS granted a U.S. citizen an extension of time to elect the provisions of Rev. Proc. 2002-23 for a Canadian Registered Retirement Savings Plan. The election, made on Form 8891 under the…
PLR 201019012: IRS rules that a QPRT amendment will not trigger IRC § 2702
The IRS ruled that the special valuation rules in IRC § 2702 would not apply to a proposed amendment and restatement of a trust holding a personal residence. The amendment would give the taxpayer's…
PLR 201019011: IRS grants relief for a late S corporation election
The IRS determined that a company had reasonable cause for failing to file its S corporation election on time. The company may make the election effective on its intended date by filing a completed…
PLR 201019010: IRS approves a retroactive QEF election for a PFIC
The IRS consented to a corporation making a retroactive qualified electing fund (QEF) election for its investment in a foreign company that qualified as a passive foreign investment company (PFIC).…
PLR 201019009: IRS treats an inadvertently invalid S election as effective
The IRS determined that a company's S corporation election was invalid because an estate and a trust beneficiary did not provide the required shareholder consents. The failure was inadvertent, so…
PLR 201019008: IRS excludes management-contract collections from gross income
The IRS ruled that amounts collected from tenants and deposited into a collection account would not be included in the taxpayer's gross income. Although the taxpayer was the nominal lessor under the…
PLR 201019007: IRS approves restatements of two qualified personal residence trusts
The IRS ruled that IRC § 2702 would not apply to proposed amendments and restatements of two trusts holding a residence. The changes would allow the taxpayers' adult children to direct the trusts to…
PLR 201019006: IRS approves restatements of two qualified personal residence trusts
The IRS ruled that IRC § 2702 would not apply to proposed amendments and restatements of two trusts holding a residence. The changes would allow the taxpayers' adult children to direct the trusts to…
PLR 201019005: IRS excludes wrongful-death damages from gross income
The IRS ruled that a taxpayer's recovery from a legislative settlement for the wrongful death of the taxpayer's child would be excluded from gross income under IRC § 104(a)(2). The recovery was for…
What these documents are
- Private letter rulings (PLRs): A taxpayer asked the IRS to rule on a planned transaction before doing it. The ruling shows exactly how the IRS applied the Code to those facts.
- Technical advice memoranda (TAMs): The IRS National Office answering a question raised during an audit or other proceeding.
- Chief Counsel advice (CCAs): IRS lawyers advising their own field staff on how to apply the law.
- Determination letters: Rulings on exempt-organization matters, such as whether an organization qualifies under § 501(c)(3) or a foundation's grant procedures pass § 4945.
- Not precedent, still useful: Under 26 U.S.C. § 6110(k)(3) none of these can be cited as precedent. They remain the best public window into how the IRS actually rules on facts like yours, and practitioners read them for exactly that.